ML20033E014

Technical Evaluation Rept on Response from Philadelphia Electric Co to Generic Ltr 88-01 Pertaining to Peach Bottom Atomic Power Station,Unit 3

ML20033E014
Person / Time
Site:	Peach Bottom
Issue date:	09/30/1989
From:	Bates R, Lakner A VIKING SYSTEMS INTERNATIONAL
To:	NRC
Shared Package
ML20033E015	List: ML20033E014 ML20033E016 ML20033H021 ML20033H023
References
CON-NRC-03-87-028, CON-NRC-3-87-28 GL-88-01, GL-88-1, NUDOCS 8909260330
Download: ML20033E014 (30)

Text

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ATTACHMLNT 2 P

FINAL A

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TECHNICAL EVALUATION REPORT ON RESPONSE FROM PHILADELPHIA ELECTRIC COMPANY j

M GENERIC LETTER 88-01 PERTAINING W THE i

PEACHBOTTOMATOMICPOWERSTATION,UllIT13 Published September, 1989 prepared by Robert C. Bates Armand Lakner i

Viking Systems International 2070 Wm. Pitt Way j

Pittsburgh, PA j

i FlN AL Prepared for:

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 I

under Contract No. NRC-03-87-028, Task Order 005 t

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ABSTRACT e

i This report contains an evaluation of the licensee (Philadelphia Electric) submittal for Peach Bottos Atomic Power Station, Unit 3 which was submitted in response to the NRC Generic Letter 88-01 in which Philadelphia Electric was requested to (1) Furnish their current plans relating to piping replacement and other measures to mitigate ICSOC, inspection, repair, and leakage detection.

(2) Indicate whether they I

plan to follow the NRC Staff positions, or propose alternative measures.

Philadelphia Electric's plans are evaluated in Section 2 of this report in terms of compliance to NRC Staff positions. Philadelphia Electric presented an alternative position concerning a change to the Technical Specification on ISI which is evaluated in Section 3 of this report.

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The Licensee, Philadelphia Electric, submitted a response to the NRC i

Generic Letter 88-01. Philadelphia Electric's response pertaining to the austenitic stainless steel piping in the Peach Botton Atomic Power Station, Unit 3 (a BWR nuclear power plant) was evaluated in terms of: (1) Their previous and planned actions to mitigate IGSOC to provide assurance of continued long-ters service.

(2) Their Inservice Inspection (ISI) Program.. (3) Their Technical Specifications pertaining to ISI and their plans to ensure that leakage detection will be in conformance with the NRC Staff position.

(4) Their plans to notify the NRC of significant flaws identified (or changes in the condition of the welds previously known to be cracked) during inspection and evaluation of such flaws.

Philadelphia Electric endorses nine of the 13 NRC Staff positions which are outlined in Generic Letter 88-01. They did not indicate endorsement or rejection of four of the NRC Staff positions (i.e., clamping devices, weld overlays, stress improvement of cracked weldments, and water chemistry). They do use controlled water efiemistry, but it probably does not include HWC (the submittals are not clear on this item).

Extensive programs of piping replacement have been conducted at Peach Bottom 3 so that most welds (234 out of 315) are IGSCC Category A.

4 The other 81 welds (mostly in the RWCU outside of containment) are i

IGSCC Category G.

i They consider that RWCU welds outside of containment are uninspectable.

Otherwise, an inspection program proposed for Peach Bottom 3 conforms with the NRC Staff positions on schedule, although the specific welds scheduled for inspection were not identified. Some uncertainty exists concerning their position on inspection methods and personnel. They declined to amend the Technical Specification to include a statement that the ISI program will comply with the NRC Staff position. Rather they proposed to include such a statement in the ISI program document.

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1' CONTENTS i

i ABSTRACT 11 SUHHARY 1

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1. INTRODUCTION l

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2. EVALUATION OF RESPONSE TO GENERIC LETTER 88-01........

2 2.1 Documents Evaluated 2.2 Review of Philadelphia Electric's Responses to Staff 3

Positions and Implementation of Those Positions t

2.3 Review of Classification of Welds, Previous 4

Mit1 Eating Actions, and Previous Inspections 4

2.3.1 Current IGSCC Classifications 7

2.3.2 Previous Mitigating Treatments 2.3.3 Welds Excluded from Scope of Generic Letter 88-01 9

9 2.3.4 Previous Inspection Programs 2.3.5 Evaluation of Previous Mitigating 10 Actions and Inspections 2.4 Current Plans for Mitigating Actions 10 11 2.4.1 Summary of Plans 11 2.4.2 Water Chemistry Control 2.4.3 Evaluation of Conformance to Staff Positions and Recommendation 11 iii

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t 12 2.5 Plans for Future Inspections 12 2.5.1 Summary of Inspection Schedules 12 2.5.2 Methods and Personnel 13 2.5.3 Saaple Expansion 13 2.5.4 Plans for Uninspectable Welds 9

13 2.5.5 Evaluation and Recommendations 2.6 Changes in the Technical Specification 15 Concerning ISI L

e 2.7 Confirmation of Leak Detection 15 in the Technical Specification 15 2.7.1 Philadelphia Electric's Position 17 2.7.2 Evaluation and Recommendation 2.8 Plans for Notification of the NRC of Flaws 17 17 2.8.1 Philadelphia Electric's Position 18 2.8.2 Evaluation and Recommendation 18

3. ALTERNATIVE POSITION......................

3.1 Changes in the Technical Specification 18 Concerning ISI 18 3.1.1 Philadelphia Electric's Position 19 3.1.2 Evaluation and Recommendation 20

4. CONCLUSIONS AND RECOMTENDATIONS 23

5. REFERENCES 4

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1. INTRODUCTION 1

Intergranular stress corrosion cracking (IGSOC) near weldsents in Boiling i

Water Reactor (BWR) piping has been occurring for almost 20 years.

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Substantial efforts in research and development have been sponsored by the BWR Owners Group for ICSCC Research, and the results of this program, along with other related work by vendors, consulting firms and confirmatory research sponsored by th6 NRC, have permitted the development of NRC Staff positions regarding the IGSOC problems. The technical basis for NRC Staff positions is detailed in Reference 1, and further background is provided in Reference 2.

The results of,these research and development programs prompted the NRC to issue Generic Letter 88-01 (see Reference 3) requesting all licensees of BWR's and holders of construction permits tot i

i (1) Furnish their current plans relating to piping replacement.

inspection, repair, and leakage detection.

(2) Indicate whether they:

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(a) Plan to follow the staff positions, or I

(b) Propose alternative measures.

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i Specifically, Generic Letter 88-01 stated that an acceptable licensee response would include the following items:

(1) Current plans regarding pipe replacement and/or other measures taken or to be taken to mitigate IGSCC and provide assurance of continued long-term piping integricy and reliability.

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(2) An inservice inspection (ISI) program to be implemented at the next refueling outage for austenitic stainless steel piping.

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(3) A change to the Technical Specifications to include a statement l

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in the section on ISI that the inservice inspection progras for piping will be in conformance with the staff positions on schedule, methods and personnel, and sample expansion.

(4) Confirmation of plans to ensure that the Technical Specification related to leakage detection will be in conformance with the 4

Staff position on leak detection.

(5) Plans to notify the NRC, in accordance with 10CFR50.55a(o),

of any flaws identified that do not meet IVB-3500 criteria of f

Section XI of the ASME Code for continued operation without evaluation, or a change found in the condition of the welds previously known to be cracked, and an evaluation of the fisws for continued used operation and/or repair plans.

This report contains a technical evaluation of the response which Philadelphia Electric (sometimes called PE in this report) submitted in response to the NRC Generic Letter 88-01 pertaining to the Peach i

Bottom Atomic Power Station, Unit 3 (hereafter called Peach Bottom 3).

2. EVALUATION OF RESPONSE TO GENERIC LETTER 88-01 This evaluation consisted of a review of the response to NRC Generic Letter 88-01 of January 25, 1988 by Philadelphia Electric pertaining to Peach Bottom 3 to determine if their performance and plans are in conformance with the NRC Staff positions or if proposed alternatives are acceptable. Proposed inspection schedules and amendments to the Technical Specification were included in the review.

2.1 Documents Evaluated Review was conducted on the information pertaining to Peach Bottom 2

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t 3 provided by the Licensee in the following documents.

(1) " Response to Generic Letter 88-01, 'NRC Position on IGSOC in Bh'R Austenitic Stainless Steel Piping' for Pesch Bottom q

Atomic Power Station," Docket Nos. 50-277 and 50-278, Philadelphia Electric Company, 2301 Market Street, P.O.

Box 8699, Philadelphia, PA 19101, August 2, 1988.

(2) " Peach Botton Atomic Power Station, Units 2 and 3. Revised Response to Generic Letter 88-01, 'NRC Position on IGSOC in Bk'R Austenitic Stainless Steel Piping,'" Docket Nos.

50-277 and 50-278, Philadelphia Electric Company, 2301 Market Street, P.O. Box 8699, Philadelphia, PA 19101, March 31, 1989.

Hereafter, in this report, these documents will be referred to as Philadelphia Electric Submittals No. I and No. 2, respectively, and collectively as the Philadelphia Electric Submittals.

2.2 Review of Philadelphia Electric's Responses to Staff Positions and Itcplementation of Those Positions.

Generic Letter 88-01 outlines 13 NRC Staff positions pertaining i

to (1) materials (2) processes, (3) water chemistry, (4) weld l

overlay, (5) partial replacement, (6) stress improvement of l

cracked weldments, (7) clamping devices, (8) crack evaluation l

and repair criteria, (9) inspection methods and personnel, (10) inspection schedules, (11) sample expansion, (12) leak detection, i

and (13) reporting requirements. Generic Letter 88-01 states l

that the licensee should indiente in their submittal whether they endorse these NRC Staff positions or propose alternative positions. The Philadelphia Electric Submittal did not specifically state acceptance or rejection of the 13 NRC Staff 3

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positions, but the Philadelphia Electric positions on most of the 13 items were implied in discussions in the Philadelphia Electric Submittals. These positions are presented in Table 1.

Note that Philadelphia Electric indicated acceptance of nine of the thirteen NRC Staff positions. Concerning processes they indicated that solution treating has been used for some welds in replacement piping, they did not indicate whether they endorse heat sink welding, and they stated that they prefer to use partial replacement rather than stress improvement for mitigating IGSCC. Philadelphia Electric did not indicate either endorsement or rejection of the NRC positions on the use of Hydrogen Water Chemistry, Weld Overlay, Stress Improvement of Cracked Weldments, or Clamping Devices. In addition, although they indicated that they endorse the NRC Staff position concerning inspection schedules, they did not supply actual P

schedules for either past or planned inspections. Concerning water chemistry: Philadelphia Electric stated that they use controlled water chemistry, but so'far as could be determined from the Philadelphia Electric Submittals, this does not involve Hydrogen Water Chemistry.

2.3 Review of Classification of Welds. Previous Mitinatina Actions, and Previous Inspections 2.3.1 Current IGSCC Classifications Table 2 provides a summary of the classifications of welds at Peach Bottom 3 into the various IGSCC categories on a system-by-system basis. IGSCC classifications of the welds are also contained on a weld-by-weld basis in the Philadelphia Electric Submittal, but they are not reproduced in this i

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t Table 1 i

Summary of PE's Responses to Staff Positions l

1 PE Has/Will PE Accepts NRC Applied Consider for Staff Position Staff Position In Past Future Use

1. Materials yes yes yes

2. Processes yes(*)

yes(*)

yes(*)

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3. Water Chemistry NI(b) yy(b)

NI(b) l

4. Weld Overlay NI no NI l

5. Partial Replacement yes yes yes

6. Stress Improvement of Cracked Weldsents NI no no

7. Clamping Devices NI no NI l

8. Crack Evaluation and i

Repair Criteria yes no yes

9. Inspection Method and Personnel yes yes yes l

10. Inspection Schedule yes(c)

NI yes(c)

11. Sample Expansion yes NI yes

12. Leak Detection yes yes yes

13. Reporting Requirements yes yes (a) Solution heat treatment of some welds in replacement piping was I

applied. Stress improvement has not been used and is not planned l

for future use. No indication was provided whether heat sink welding has been or will be used.

i (b) Water chemistry control applied, but so far as it is possible to determine from the Philadelphia Electric Submittals, it does not include HWC.

(c) Neither previous nor planned inspection schedules and results were l

submitted, but PE stated that schedules would comply with NRC Staff position.

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Table 2 e

Summary of IGS00 Classification of Welds in Peach Bottos 3 i

Number of Welds of Indicated IGS00 Catenory System A

B C

D E

F G

Totelo j

Recire.

81 0

0 0

0 0

0 81 RHR 17 0

0 0

0 0

0 17 C.S.

95 0

0 0

0 0

0 95 RWCU-1 20 0

0 0

0 0

0 20 RWCU-2 19 0

0 0

0 0

77 96 RPV-Noz 2

0 0

0 0

0 4

6 Totals 234 0

0 0

0 0

81 315 Explanation of abbreviations:

Rectrc. - Reactor Recirculation (includes nozzles N1 and N2)

RHR

- Residual Heat Removal C.S.

- Core Spray (includes nozzle N5)

RWCU Reactor Water Cleanup from RHR to outer containment i

isolation valve RWCU Reactor Water Cleanup beyond outer containment isolation valve RPV

- Reactor Pressure Vessel l

Noz

- Nozzles

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i report. Note that four nozzle to safe-end welds and most of the piping that is outboard of the containment isolation valve in the Reactor Water Cleanup system contains non-conforming asterial and is classified as IGSCC Category G welds. However, all of the other welds in in Peach Bottos 3 are IGSCC Category A welds.

Philadelphia Electric Submittal No. 1 states the following concerning the IGSCC classifications of certain of the RWCU and Core Spray welds:

"The selection of NRC Generic Letter 88-01 IGSCC categories resulted from thoroughly researching currently available documentation containing piping and welding characteristics applicable to IGSCC resistance."

"The information necessary to determine IGSCC resistance has been partially indeterminable for a Ilmited number of cases (e.g. delta ferrite ASTM A262-A testing, etc.).

IGSCC categories for these velds have been selected by comparing characteristics of similar welds of known composition, applying typical or average characteristics to known materials, and performing a metallurgical assessment from experience obtained through the pipe replacement effort."

2.3.2 Previous Mitimatinn Treatments Philadelphia Electric has chosen to apply piping replacement as the preferred method of mitigating IGSCC rather than applying stress improvement treatments. The large number of IGSCC Category A welds is the result of extensive piping replacement programs. These piping replacement programs are summarized in Table 3 of this report.

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Table 3 P

i Summary of Piping Replacement at Peach Botton 3 Material (see note a)

M System Pipina/Forninas Field Welds Categ.

ReactorRecirculsgn Suction Piping 316SS Cont. Chem.

<.02 C, 8FN A

Discharge Piping (b) 316SS Cont. Chem.

<.02 C, 8FN A

N1 & N2 Nozzle 316SS Cont. Chem.

see note (c)

A Safe-Ends 4

Residual Heat Removal 316SS Cont. Chem.

<.02 C, 8FN A

Core Spray Piping 316L (<.02 C)

E308L(d)

A i

RPV N5 Nozzle / Safe-end Type 316HG see note (c)

A RWCU(') - Section A 316L (<.02 C)

E308L(d) g

- Section B 316SS Cont. Chem.

<.02 C, 8FN A

- Section C Non-conforming Non-conforming G

RPVS - Jet Pump Inst.

Penetration Seals, integral with safe-ends Safe-Ends, and Welds NB & N9 316SS Cont. Chem.

low C, 8FN-A

,N10, Nil, N12,8 N16 Non-conforming Non-conforming G

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(a) 316SS Cont. Chem. (controlled chemistry) contains <0.02 carbon and i

nitrogen additions for added strength.

(b) Meets General Electric document E50YP11 for intergranular attack, and shop welds were solution treated after welding.

(c) Nozzle to safe-end weld butter is Inconel 182 clad with Inconel 82, or it has been replaced with Type 309L or 309L/308L' butter combination i

j followed by local post weld heat treatment of the nozzle.

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(d) Complete composition has not been confirmed for some of the RWCU L

welds, but for those that have been confirmed, the material is E308L.

l Similarly, information necessary to determine IGSCC resistance is partially indeterminable for some Core Spray and RWCU welds. For these cases, the IGSCC classifications are based on comparisons with similar welds of known composition and IGSCC resistance.

j (e) RWCU - See text for description of piping in Sections A, B, and C.

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In Table 3, certain sections of the RWCU piping are designated t

as Section A, Section.B, and Section C.

These sections l

include piping as follows:

Section A includes piping from the connection at the RHR pump suction piping up to the downstream weld on the last elbow prior to primary containment penetration N-14.

Section B includes the 4" piping from the yrimary containment penetration, the penetration itself, and 4

outboard piping from the penetration to the regenerative heat exchanger.

Section C includes the balance of the 4" RWCU piping.

2.3.3 Welds Excluded from the Scope of Generic Letter 88-01 4

Certain portions of the Residual Heat Removal (RHR) and the Core Spray systems, according to the Philadelphia Electric Submittal, operate at temperatures below 200'F and are, therefore, outside of the scope of Generic Letter 88-01.

These sections of piping are as follows:

RHR piping beyond valves A0-46A and B and piping beyond valve MO-18.

Core Spray piping beyond valves 14A and B.

2.3.4 Previous Inspection Programs The Philadelphia Electric Submittal did not provide any information concerning previous inspections of welds in Peach Bottom 3.

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t 2.3.5 Evaluation of Previous Mitimatina Actions and Inspections An extensive piping replacement program has been conducted at Peach Bottom 3 with the result that 234 of the 315 welds i

that are within the scope of Generic Letter 88-01 are IGSOC Category A welds. However four noaales to safe-ends (NIO, I

Nil, N12, and N16) and 77 of the 96 welds in the RWCU that are outboard of the isolation valves contain non-resistant material. None of the welds that contain non-resistant material have been inspected so they are classified as IGSOC Category G welds.

PhiladelphiaElectricexNrienceddifficultyfindingsome of the data (composition and/or IGSOC resistance) required s

i for classification of some of the welds in replacement piping, but the approach they took in comparing those welds with other similar welds with knowr. composition and IGSOC resistance is a technically valid approach, and acceptance of Philadelphia Electric's IGSCO' classifications is recommended.

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Since no previous inspections were reported, no evaluation of such inspections (if any were performed) can be provided 2

in this report.

I 2.4 Current Plans for Mitinatina Actions l

2.4.1 Summary of Plans a

Philadelphia Electric stated that stress improvement of unmitigated welds is not planned. Rather, the thrust of l

their IGSCC mitigation program at Peach Bottom 3 is to replace 10 0

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i susceptible piping with resistant materis1. However, no j

plan for additional piping replacement is contained in the l

I Philadelphia Electric Submittals. Water chemistry control, an augmented inspection program, and leakage detection are planned as discussed below.

4 2.4.2, Water Chemirtry Control Philadelphia Electric Submittal No.1 contains the following i

statement concerning water chemistry controls

" Water chemistry control at Peach Botton 3 is detailed in Rev. O of Philadelphia Electric Company's "BWR Water Chemistry Control Program", dated Deceober 11, 1987.

The water chemistry control requirements in this program are in accordance with the BWR Owners Group and Electric Power Research Institute (EPRI) Water Chemistry Guidelines, existing General Electric chemistry recommendations and INPO recommendations."

2.4.3 Evaluation of Conformance to Staff Posittens and Recommendation i

Extensive Mitigating actions have already been applied, so l

l that 234 of the 315 welds at Peach Bottom 3 that are within i

the scope of Generic Letter 88-01 are classified as IGS(X:

Category A.

Except for the portion of the RWCU that is l

outside of the containment isolation valve, only four welds remain unmitigated. 'Ihus, except for the welds other the the 77 IGSCC Category G welds outside of containment (for which a UT inspection program is needed as discussed below),

acceptance of Philadelphia Electric's position is recommended.

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2.5 Plans fer Tuture Insnections l

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2.5.1 Sa rr of Inspection tekadules l

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Philadelphia Electric Submittal No. 1 states that the inspection schedules for Peach 50ttau 3 are being revised j'

to reflect the requirements for inspection schedules as l

delineated ta NUREG 0313. Revision 2 and Generic latter 88-01.

Philadelphia Electric Submittal No.1 contates a list of l

velds to be included in the planning the inspection schedules however, actual inspection schedules were not provided.

In addition, two'IGSOC Category A nossle to safe-end volda l

(N8 and N9) and four IGSCC Category G nozzle te safe-end welds (N10, N11, W12, and N16), although listed ta the submittal, are not included in the list of velds that are considered to be in the scope of Generic Letter 88-01.

2.5.2 Methods and Personnel The Philadelphia Electric Submittel states that inspection methods and personnel qualifications will comply with the NRC Staff position as delineated in Generic Letter 88-01.

It further states: (1) For ultrasonic tea ing inspectable ASE Class 1 and 2 velds, the IGSCC inspections vill menerally be performed in accordance with the requirements contained in the applicable edition and addenda of ASE Section II for the ASE class of weldsent. (2) For ultrasonically inspectable ASE Class 3 and non-cissa velds, the requirements in Section 11 for Class 2 velds vill apply. (3) The edition and addenda of ASE Section II used for determining these requirceents vill be as dictated by paragraph (3) of 10CFR$0.b$a.

(4) The personnel performing the IGSCC volumetrit inspections vill be qualified for such inspections by a formal program approvad by the NRC.

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l-2.5.3 Sassle Espansion Philadelphia Electric's position on Sample Espansion is in compliance with the NRC Staff position. Specifically, if one or more Category A B, or C welds are found to be cracked, or if odditional cracks or significant crack growth is discovered in a Category E weld during the interval, a sample expansion plan will be invoked which will be in accordance with the NRC Staff position on Sample Espansion as delineated in Generic Letter 88-01.

2.5.4 Plans for Uninsoectable Welds The RWCU welds outside of containment are presently considered to be uninspectable by UT. Philadelphia Electric plans to verify the integrity of these welds by pressure tests in accordance with the requirements of Section XI Article IWB, IWC, or IWD-5000, and they plan to revise the Peach Botton 3 pressure test procedures to incorporate this portion of the RVCU system. The reason these welds are considered to be uninspectable was not provided.

2.5.5 Ivatustion and Recommendations Philadelphia Electric stated that they will follow the NRC Staff position on inspection schedules (with the exception of the RWCU welds that are outside containment), so acceptance of their position on inspection schedules for welds other than the RWCU welds outside of containment is recommended.

However, two action items are also recommended:

(1) The list of welds that are included in the Peach Bottom 3 ICSCC program should be modified to include 13 o

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b 67 the Mr nossle to safe-end welds included is their submittel but esitted from the octual list.

(2) Philadelphia Electric should submit (to the NRC Staff) actual inspection schedules which verify their statement that schedules will follow requirements i

of Generic Letter 88-01.

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The reasons that RWCU welds outside of containment are f

considered to be uninspectable were not provided so it is j

not possible to evaluate the claim of uninspectability.

It is presumed in this report, however, that these volds are not actually uninspectable because most such welde in numerous other BVR nuclear plants are inspectable. 1hus, it is recommended that Philadelphia Electric should either i

demonstrate that those welds are uninspectable or amend their IGSCC UT Inspection progran to include the RWCU welds that j

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i are outside of containment.

4 Although Philadelphia Electric stated that they are committed l

to complying with the NRC Staff positions on Anspection l

l methods and personnel as dalineated in Generic Letter 88-j i

01, they also stated that ultrasonic testir.g of inspectable 1

ASE Class 1 and 2 welds will senerally be performed in r

l accordance with the requirements contained in the. applicable f

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edition and addenda of ASE Section II for the ASE class of weldment. The term " generally" implies that there vill I

be exceptions and deviations from their stated position of compliance with the requirements of Generic Letter 88-01.

f Thus, rejection of their position on this item is recommended.

Philadelphia should amend their position concerning inspection t

methods and personnel to be in total compliance with the NRC Staff position.

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4 Philadelphia Electric's posittom on oasple espansion is in compliance with the NRC Staff position, so acceptance of I

this position is recommended.

2.6 Channes in the Technical Soecification Concernina ISI Philadelphia Electric Submittal No. I states that a change to the Technical Specifications will be proposed and subsitted by December 31, 1968. The proposed change 'v111 add the following statement to Section 4.6.G of the Peach Botton 3 Technical Specification:

"The Inservice Inspection (ISI) Program for piping identified in the NRC Generic Letter 88-01 shall be performed in accordance with the staf f positions on schedule, methods and personnel, and sample expansion included in NRC Generic Letter 88-01.

Details for the toplementation of these requirements are included as augmented inspection requirements in the ISI progras."

Philadelphia Electric also stated that a similar statement would be added to the Peach Bottom 3 FSAR, Appendix I, page I-1, which controls the ISI program.

However, their position is revised in Philadelphia Submittal No.

2 which presents an alternative position. That alternative position is reviewed in Section 3 of this report.

2.7 Confirmation of Leak Detection in the Technical Soecification 2.7.1 Philadelphia Electric's Position Philadelphia Electric Submittal No. I states that the existing 15 I

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l Technical Specifications are in conformance with the NRC Staff position on leakage.

It further states that the Peach l

Botton Technical Specifications 3.6.C and 4.6.C contain the fc110 wing "The Technical Specifications require that Reactor Coolant unidentified leakage shall be limited to 5 sps or the unit shall be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and is cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

"The Technical Specifications require that the rate of change of Reactor Coo'lant' unidentified leakage shall not exceed 2 sps within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or the unit shall be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

"The Technical Specifications require that total Reactor Coolant Systes leakage be limited to 25 sps averaged over any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance period or the unit shall be in hot shutdown within 12' hours and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

"The Technical Specifications require that the primary containment (drywell) susp collection and flow sonitoring system be operable during reactor power operation. From and after the time the systes is made or found to be inoperable for any reason, reactor power operation is permissible only during the succeeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the system is made operable sooner. Operability of this system is defined as the ability to measure reactor coolant leakage."

"The Technical Specifications require that the Drywell Atmosphere Radioactivity Monitor shall be operable during 16 f

reactor power operation as a supplement to the reactor coolant leakage monitoring system. Free and after the time the system is made or found to be inoperable for any reason, reactor power operation is pomissible for j

up to 30 days provided grab ansples of the containment j

atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" "The Technical Specifications require tht the drywell atmosphere radioactivity levels shall be monitored and recorded at least once per day."

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f "The Technical Specifications require that Reactor Coolant j

System leakage be monitored and recorded every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> using the primary containment (drywell) sump collection and flow monitoring system."

I 2.7.2 Evaluation and Recommendation i

The Peach Bottos 3 Technical Specifications pertaining to Leakage Requirements are currently in compliance with the NRC Staff position as delineated in Generic Letter 88-01.

It is recommended, therefore, that the Philadelphia Electric

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position on leakage should be accepted.

2.8 Plans for Notification of the NRC of Flaws 2.8.1 Philadelphia Electric's Position Philadelphia Electric plans to adopt the NRC Staff position on notification. If any flaws are identified which do not meet the referenced criteria for continued operation, the NRC will be duly notified of the disposition of the affected 17 9

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flaws, and NRC approval of the disposition for each flaw exceeding the criteria will be obtained before operation is resweed.

Pertaining to evaluation of flaws: Flave exceedtag the acceptanca criteria of IW5-3M10 of ASME Section II will be evaluated, then either repaired, replaced or deemed acceptable for continued operation. Repairs or replacements will be documented in the Owners Report for Repairs and Replacements as required by ASNE Section II. Evaluations of flaws for continued operation will be performed in accordance with the requirements of NUREG 0313. Revision 2 in conjunction with the criteria in IVB-3600.

2.8.2 Evaluation and Recommendation Since Philadelphia Electric plans to comply with the NRC Staff position, it is recommended that the plans for reporting of flaws and evaluation of flaws should be accepted.

3. ALTERNATIVE POSITION 3.1 Alternative Position Concerninn ISI in the Technical Specification 3.1.1 Philadelphia Electric's Position As indicated in Section 2.6 of this report, Philadelphia l

Electric initially agreed to amand the Peach Bottos 3 Technical Specification on ISI to include a statement that the inservice inspection program would comply with the NRC f

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Staff position on inspection schedules, methods and personnel, f

l and sample expansion. liowever, that position was revised i

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i as stated in Philadelphia Electric Submittel No. 2 which r

statest L

i "Upon review of other licenseos' responses to Itos 3 and subsequent discussions with the I4ad WRC Project l

Manager for this Generic letter, we have concluded that inserting the recommended statement into the Technical Specifications is not necesesty or appropriate.

j the staff positions on Intergranular Stress Corrosion l

Cra<, king (IGSOC) vill be incorporated into our ISI Program f

document. This position is consistent with the philosophy l

of the Technical Specifications Improvement Program which f

encourages the relocation of various specifications to other licensee controlled documents. Therefore, this i

letter amends our original response to Ites 3 of Generic l

Letter 88-01 by withdrawing our commitment to propose l

I an amendment to the Technical Specific.ations concerning our ISI Progras."

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3.1.2 Evaluetton and Recommendation Philadelphia Electric's stated position is that the ISI program document for Peach Bottos 3 vill incorporate a statement that the ISI program vill comply with the NRC Staff l

position. This does not adequately fulfill or substitute l

l for the requirement that such a statement should be i

incorporated into the Technical Specification. In fact,

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Generic Letter,88-01 specifically rejects the approach of j

placing the statement in the ISI program document. 'Ihus,

rejection of Philadelphia Electric's position is recommended.

i It is further recommended that Philadelphia Electric should f

amend the Technical Specification on ISI as required by l

Generic Letter 88-01.

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4. CONCLUSIONS AND RE00WDfDATIONS i

l Philadelphia Electric endorsed nine of the thirteen NRC Staff positions

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as delineated in Generic Letter 88-01 (i.e., those pertaining to j

materials, processes, partial replacement, crack evaluation and repair l

criteria, inspection methods and personnel, inspection schedule, sample l

expansion, leakage detection, and reporting requirements).

Concerning j

processes, Philadelphia has applied solution treating but they have l

not applied stress improvement or heat sink weldias hoy did not provide an indication of acceptance or rejection of the NRC Staff f

positions concerning veld overlay, stress improvement of cracked weldsents, and clasping devices. Concerning water chemistry, they indicated that they use controlled water chemistry, but as best as i

it could be determined from their submittals, the water chemistry control at Peach Bottom 3 does not involve hydrogen water chemistry.

I Most of the welds (234 out of a total of 315) at Peach Bottos 3 are IGSCC Category A welds. This large number is the result of extensive The remaining piping replacement programs conducted at Peach Bottos 3.

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81 welds contain non-resistant material and none of these has been l

inspected. Thus Peach Bottos 3 has IGSCC Category G welds, 77 of which j

i are in the RWCU outside of containment.

i The thrust of the Philadelphia Electric program at Peach Bottos 3 is

however, l

piping ieplacement/ removal rather than stress improvement

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no additional piping removal is scheduled. As mentioned above, they also plan to continue water chemistry control (but not HWC).

l Philadelphia Electric agreed to comply with the NRC Staff positions concerning inspection schedules, inspection methods and personnel, r

sample expansion, and reporting requirements. They did not submit actual inspection schedules which confirm their statement of compliance with the NRC Staff position, but they did submit a list of welds that fall within the scope of Generic Letter 88-01. However, they excluded J

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t O s four nozzle to safe-end welds from that list (although these wlds f7 a

are discussed in Philadelphia Electric Submittal No. 1), and in

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elaborating on their conferianace with the NRC Staff position on inspection methods, theyisoded two provisions (or eaceptions).

First, 4

they stated that RWC0 welds outside of containment are considered as I

1 inaccessible for UT inspection. h ey plan hydrostatic tests of that j

Second, they stated that UT inspections will generally be piping.

l conducted in accordance with requirements of ASME Sectica II, and the l

word " generally" implies exceptions (although no specific esceptions were detailed in their subeittal). hose provisions are unacceptable.

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Philadelphia Electric initially agreed to change the Technical

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Specification concerning ISI, and they stated that a proposed amendment f

l would be submitted by December, 1988. Later, they changed their I

position and stated that the required statement would be added to the his ISI program document rather than the Technical Specification.

approach is specifically rejected in Generic Intter 88-01.

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The Technical Specification concerning leakage is already in compliance j

with the NRC Staff position as delineated in Generic Letter 88-01.

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As a result of this technical evaluation, the following recommendations j

are made, (1) Acceptance of Philadelphia Electric's position on mitigation f

of IGSCC and their assignment of IGSOC Classifications of welds in Pesch Bottes 3.

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(2) Tentative acceptance of Philadelphia Electric's plans pertaining l

to inspection schedules (except for the RWCU w lds outside j

j of containment) pending confirmation (with actual inspection schedules) of their announced intention of compliance with l

j the NRC Staff position.

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(3) Unless Philadelphia Electric can demonstrate that the Rip i

velds outside containment are really inaccessible (rather than

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just considered oo), these welds should be included in 10000

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UT inspection plan and inspected is accordance with the schedule l

outlined in Generic Letter 86-01 for IGSOC Category G welds.

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f (4) Rejection of Philadelphia Electric's position en inspection l

methods and personnel until they eliminate or acceptably clarify

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the word " generally" which was used in their descripties of their plans.

(5) Acceptance of Philadelphia Electric's position on enspie i

i expansion.

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(6) Rejection of Philadelphia Electric's position on changing the j

Technical Specification concerning ISI. Philadelphia Electric should amend the Pasch Botton 3 Technical Specification as l

initially promised in their original submittal (Philadelphia

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Electric Submittal No. 1).

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I (7) Acceptance of Philadelphia Electric's posit %n concerning the j

Technical Specification on leakage detectiva.

(8) Acceptance of the remaining portions of the Philadelphia Electric Submittals.

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5. RDERENCES l

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1.

" Technical report on Material Selection and Processing Guidelines l

for BWR Coolant Pressure Boundary Piping," NUREG 0313 Revision

2. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, January,1988.

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t 2.

" Investigation and Evaluation of Stress e rrosion Cracking in Piping

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of Light Water Reactor Plants," NUltBG 0531, U. S. Nuclear Regulatory f

Conaission, February, 1979.

I "NRC Position on IGSOC in BWR Austenitic Stainless Steel Piping,"

f 3.

Generic latter 88-01, U.S. Nuclear Regulatory Commission, January l

25, 1988.

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ENCLO$URE 2 REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO GL 88 01 FOR PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 1.

The Technical Specifications need to be amended to include a statement that the inservice inspection program for piping covered by the scope of GL 88 01 will be in conformance wnth the staff positions on schedule methods and personnel, and sample expansion. PleaseprovidearevisN connitment for this item, with a proposed schedule for submitting an appropriate amendment application.

2.

Please indicate whether PEco intends to follow the staff positions presented in GL 88-01 on water chemistry, weld overlay reinforcement, stress improvement of cracted weldments, and clamping devicess or propose alternative measures, in addition, the staff's safety evaluation and associated technical evaluation reports presented the staff's understanding of the licensee's position on the remaining nine subjects discussed in GL 88 01.

Please understarding of your position. provide corrections, if any, to the staff's 3.

With respect to inspection methods and personnel, the licensee stated that ultrasonic testing of inspectable ASME Class 1 and 2 welds will generall be performed in accordance with ASME Section XI requirements, which im lied that there will be exceptions and deviations. Please clarify hether there will be exceptions and deviations; and if so, provide a discussion on whether this is consistent with the NRC position presented in GL 88-01, 4

Pleese provide the reasons that reactor water cleanup system welds located outside containment are considered to be uninspectable.

E.

Please provide actual inspection plans in tabular form using a format such as that illustrated in Table 3 of the Request for Additional Information transmitted in a June 16, 1989 letter.

e

i o...

Mr. George A. Hunger, Jr.

Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3 i

cc:

l Troy B. Conner, Jr., Esq.

Single Point of Contact I

1747 Pennsylvania Avenue, N.W.

P. O. Box 11880 i

l Washington, D.C.

20006 Harrisburg, Pennsylvania 17108-1880 l

Philadelphia Electric Company Mr. Thomas M. Servsky, Director i

ATTN: Mr. D. M. Smith, Vice President Bureau of Radiation Protection l

Peach Bottom Atomic Power Station Pennsylvania Department of 2

Route 1. Box 208 Environmental Resources i

Delta, Pennsylvania 17314 P. O. Box 2063 Harrisburg, Pennsylvania 17120 a

Philadelphia Electric Company ATTN: Regulatory Engineer, A1-25 Mr. Albert R. Steel, Chairman Peach Bottom Atomic Power Station Board of Supervisors Route 1, Box 208 Peach Bottom Township Delta, Pennsylvania 17314 R. D. #1 Delta, Pennsylvanie 17314 1

Retident inspector U.S. Nuclear Regulatory Comission Public Service Comission of Maryland Peach Bottom Atomic Power Station Engineering Division P.O. Bex 399 ATTN: Chief Erejineer Delta, Pennsylvania 17314 231 E. Baltimore Street Baltimore, MD 21202-3486 Regional Administrator, Region !

l V.S. Nuclear Regulatory Comission Mr. Tom Magette 470 Allendale Road Power Plant Research Program King of Prussia, Pennsylvania 19406 Department of Natural Resources B-3 1

Mr. Peland Fletcher Tawes State Office Building i

Department of Environment Annapolis, Maryland 21401 l

201 West Preston Street l

Baltimore, Maryland 21201 l

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